Richard Denison, Ph.D., is a Senior Scientist.

When the chemical industry talks about prioritization – a central question in the debate over TSCA reform – more often than not it quickly reduces the question down to the argument that we should focus only on those chemicals, however hazardous or untested they may be, to which we know people are exposed.  In a perfect world, that might suffice.  But, as this post will explore, the world of exposure assessment is anything but perfect.  Read more »

Richard Denison, Ph.D., is a Senior Scientist.

Today, EPA Administrator Lisa Jackson unveiled the Obama Administration's "Essential Principles for Reform of Chemicals Management Legislation."  The principles' significance lies not so much in the words they contain, but rather in what they symbolize:  A clear confirmation that this Administration understands that the Toxic Substances Control Act (TSCA) needs fundamental reform and that it is ready and willing to engage in making it happen. Read more »

Richard Denison, Ph.D., is a Senior Scientist.

Today, the American Chemistry Council (ACC) unveiled its "10 Principles for Modernizing TSCA."  Also today, the Safer Chemicals, Healthy Families coalition – of which EDF is a member – issued a news release and unveiled its 9-point "Platform for Reform of TSCA."  How do they line up? Read more »

Richard Denison, Ph.D., is a Senior Scientist.

Some time back, I promised a look at whether Canada's Chemical Management Plan provides a model for TSCA reform.  This post will provide that look.  Bottom line:  While our neighbor to the north has undertaken and accomplished a great deal over the past decade, it has done so with one hand tied behind its back.  Read more »

Richard Denison, Ph.D., is a Senior Scientist.

This new post serves as a response to Charlie Auer's most recent comment responding to our critique of ChAMP.  (To see the whole exchange, start here, then go here, here and here.)  So far, this exchange has focused mainly on our disagreement over whether or not EPA is somehow required to do risk assessments under ChAMP.  At some point, I hope Charlie and others will engage on the substance of our critique – the serious concerns we've raised about the quality and validity of the ChAMP assessments.
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Richard Denison, Ph.D., is a Senior Scientist.

[Note:  This post was originally posted as a comment on Gina Solomon's blog post on Huffington Post.  The context is a pending budget proposal from the Governor's office in California to eliminate the State's Office of Environmental Health Hazard Assessment (OEHHA) under CalEPA and disperse some but not all of its functions to other agencies.  This proposal, if implemented, would in my view be truly tragic.  If you agree, make your voice heard!]  Read more »

Richard Denison, Ph.D., is a Senior Scientist.

As I noted in our first post on ChAMP, after getting off to a strong start in 2007, EPA's abrupt decision in 2008 to steer ChAMP in the direction of cranking out hasty risk decisions was entirely its own.  Can ChAMP be put back on track?  Read more »

Cal Baier-Anderson, Ph.D., is a Health Scientist and Richard Denison, Ph.D., is a Senior Scientist.

This example raises some new issues as well as some we discussed in the earlier examples:  EPA relies on a highly flawed "category approach" that ignores major differences in the properties and structures of the 13 members of this category.  It compounds this problem by unquestioningly accepting data from inadequate studies to assert low toxicity, rather than demanding that sufficient studies be provided.  As a result, it fails to identify, let alone require to be filled, the enormous gaps in the data available for many of the category members.  EPA ignores or dismisses without explanation its own earlier comments raising serious concerns about the quality and completeness of data provided by the sponsor of these chemicals under the HPV Challenge.  Finally, this example once again shows how EPA's heavy reliance on self-reported use information from manufacturers paints an incomplete and potentially very misleading picture of the actual uses of industrial chemicals.  Read more »

Cal Baier-Anderson, Ph.D., is a Health Scientist and Richard Denison, Ph.D., is a Senior Scientist.

Our analysis of EPA's risk decision under ChAMP for this category of toxic chemicals vividly illustrates how EPA has failed to adopt a health-protective approach to its screening of HPV chemicals.  Rather, it misclassifies or understates these chemicals' hazards, asserts that existing regulations are sufficient even when they are quite old or do not cover identified exposures, and naively assumes that children will not be as exposed as adults to consumer products used in the home unless they are intended for their use.  Finally, this case demonstrates that manufacturers are not reporting to EPA even readily available information on their chemicals' uses.  Read more »

Cal Baier-Anderson, Ph.D., is a Health Scientist and Richard Denison, Ph.D., is a Senior Scientist.

This post is the first of a number to come that will examine in some detail specific chemicals and chemical categories for which EPA has made questionable or flawed risk decisions under ChAMP. Many of these problems can be traced to EPA's near-exclusive reliance on incomplete or poor-quality data provided by manufacturers, or its need to resort to unsupported assumptions in the absence of sufficient data. For each posting, we'll summarize what is known about production and use of the chemical(s); describe EPA's hazard, exposure, risk and priority rankings; and then discuss why we question or disagree with EPA's decisions. First up: a category of three alkyl nitriles. Read more »